IKE Scenario 06-03 Performing 03J01 & 03J02 Procedures for the Determination Compliance with the Food Safety Standard for Fecal Material, Ingesta and Milk on Livestock Carcasses During Slaughter Operations.

This IKE scenario is the second of three that are designed to illustrate the procedures used in accordance with FSIS Directive 6420.1, Livestock Post-Mortem Inspection Activities – Enforcing the Zero Tolerances for Fecal material, Ingesta and Milk, dated 12/17/98. This directive provides instructions to inspection personnel that are similar to FSIS Directive 6150.1, Rev. 1, Poultry Post-Mortem Inspection and Reinspection – Enforcement of Zero Tolerance for Visible Fecal Material, dated 6/19/98. 

You are an on-line GS-7 slaughter inspector in the same young, fat cattle slaughter facility described in IKE 05-03. Your duties involve performing post-mortem inspection of the cattle. This includes, in addition to pathology, detecting food safety defects, such as contamination with feces, ingesta or milk, as well as detecting other dressing defects (e.g., hair, scurf) on individual carcasses. In doing so, your post-mortem inspection takes into account the on-going effectiveness of the establishment’s food safety and other-consumer-protection controls.

During the post-mortem final rail inspection procedure you observe individual beef carcasses exhibiting readily identifiable visible fecal material on the round. Note: readily identifiable fecal material is identified as yellow, green, or brown material containing fibrous or plant-like textures in accordance with FSIS Directive 6420.1. Each time you detect feces you stop the line or, since the establishment has a rail-out loop as described in FSIS Directive 6420.1, you inform the establishment trimmer assigned to the station, who then rails the affected carcasses out for re-examination and re-work of the entire carcass. The establishment subsequently re-examines the entire carcass and trims all identifiable feces, ingesta and milk contamination from the carcasses and positions them back on-line for final rail inspection.

As a critical thinker, what do you think the next actions should be by the on-site FSIS in-plant team assigned to the establishment?

· You, as the on-line Food Inspector, will continue to perform post-mortem inspection on each carcass as described above. As part of this process, one of your responsibilities is to communicate with off-line inspection personnel (the IIC or CSI when you have reason to believe that the establishment’s process is out of control. In this instance, you have observed a higher-than-normal frequency (number of defects over a period of time) of contaminated carcasses and ring for the IIC and/or CSI to inform them of your observations.


· After a discussion with the on-line inspector, the off-line CSI considers what to do next and decides to perform an 03J01 procedure to verify whether the establishment’s food safety control system is adequately meeting the FSIS food safety standard.

· As part of the 03J01 procedure the off-line CSI selects 11 carcass units as per FSIS Directive 6420.1 to verify the establishment is meeting the food safety standard. Additionally, as part of the same 03J01 procedure the off-line CSI verifies the correctives actions that the establishment has put in place to address previous failures to meet the food safety standard.

· All carcass units are examined on-line by the off-line CSI, as per FSIS Directive 6420.1. No fecal, ingesta, or milk contamination is found on the carcass units.

· Next, the off-line CSI verifies the effectiveness of the establishment’s previous corrective actions. During the previous day, the off-line CSI observed two of eleven beef carcasses that exhibited readily identifiable fecal material on the round while performing an 03J01 verification procedure for the Agency’s food safety standard for fecal material, ingesta, and milk. The corrective actions documented by the plant in response to these failures, stated that they would retrain new establishment employees assigned to the hiding operation. They also stated that the plant would initiate a program for inspecting the live cattle for excessive contamination, and removing the contamination prior to the live cattle entering the plant (see IKE 05-03). The off-line CSI determines that the establishment has not yet trained the new employees assigned to the hiding operation. In fact, they have additional employees with no experience in the hiding operation. Additionally, the off-line CSI determines that the plant has documented a plan for inspecting the live cattle, but they are not following the program as it is documented. The plant does inspect the live cattle, but has not implemented the measures to remove contamination from the live cattle. The off-line CSI determines that the establishment has failed to meet the corrective action requirements of 9 CFR 417.3(a). They document an NR on FSIS Form 5400-4 and mark the corrective action trend indicator based on the establishment’s failure to implement these preventive measures.

· Remember: The 03J01 and 03J02 procedures should include verification of corrective actions, as appropriate. This activity is in addition to the off-line CSI verifying the carcass units for fecal, ingesta, or milk contamination.

· An 03J02 verification procedure is then performed to verify that the establishment’s corrective actions were implemented and effective. The off-line CSI continues to verify the preventive measures offered by the establishment as part of his/her on-going verification of the slaughter food safety system.

This IKE scenario is an example that clearly demonstrates the importance of all members of the in-plant food safety inspection team. While the post-mortem inspector has responsibility for inspecting carcass by carcass, they work closely with the off-line inspection team when they question that the process may be out of control.

For IKE related questions, send mail to ike@fsis.usda.gov. For all other general questions, send to Tech Center address listed below.